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IN RE KREIDLE

Civ. A. No. 91-C-1245.

143 B.R. 941 (1992)

In re James D. KREIDLE, Debtor. James D. KREIDLE, Plaintiff and Appellee, v. DEPARTMENT OF THE TREASURY, INTERNAL REVENUE SERVICE, Defendant and Appellant.

United States District Court, D. Colorado.

August 20, 1992.

Attorney(s) appearing for the Case

Harry Sterling, Denver, Colo., for plaintiff and appellee.

Mark Nebergall, U.S. Dept. of Justice, Washington, D.C., for defendant and appellant.

MEMORANDUM OPINION AND ORDER

CARRIGAN, District Judge.

Appellant, Internal Revenue Service (IRS), appeals the order of the United States Bankruptcy Court for the District of Colorado in favor of Appellee/Debtor James D. Kreidle.

The parties have fully briefed the issues and oral argument would not be helpful. Jurisdiction is alleged under 28 U.S.C. § 158(a).

I. FACTS.

James D. Kreidle was a fifty percent partner in Titsch ...

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